Telehealth Policy

Medicare telehealth policy has shifted dramatically for the entire healthcare industry in response to COVID-19, both policy unique to RHCs and more broadly within the fee-for-service community. 

Table 1 breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.

All RHCs billing for telehealth should review the MLN Matters document: New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE).

In December 2020 CMS announced significant telehealth coinsurance changes.

Beginning January 2022 and not connected to the PHE, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.

NARHC continues to advocate for permanent coverage of all telehealth services and a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.Table 2 highlights the various Medicare telehealth waivers and their current status as of fall 2023.

With any questions, please email Sarah Hohman at

Table 1

Name of Telehealth Service

Brief Description

How to Bill

Reimbursement Rate


Virtual Check-In or Virtual Care Communications

Remote evaluation - G2010
Brief communication with patient (5 min) - G2012

Bill on UB-04
No modifier necessary
Rev Code





Digital e-Visits

Online evaluation and management



Bill on UB-04
No modifier
Rev Code 052X



Only billable
during the
May 11, 2023).

Telehealth Visits

One to one substitutes for in-person services/visits

List of allowable services maintained by CMS
(including services allowed via audio-only)

Bill on UB-04 Modifier 95 optional
Modifier CS (for services where cost sharing is waived

Rev Code 052X

Costs and encounters carved out of cost report



set to expire
December 31, 2024

Mental Health
Telehealth Visits

One to one substitutes for in-person mental health services/visits

CPT codes that can be billed with 0900 revenue code

Rev Code 0900

Use proper mental health CPT code

Modifier CG always

Modifier 95 if audio-video

Modifier FQ or 93 if audio-only
Count costs and encounters on cost report


January 1, 2022

*Occasional in-person
visit requirement
begin on
January 1, 2025


Chronic Care Management/
Principal Care Management
99484, 99487, 99490, 99491, 99424, and 99425 = G0511
99492, 99493 = G0512

G0511- Care Management

G0512- Psychiatric Care Management

G0511 2022-

G0511 2023-

G0512 2022-

G0512 2023-

Transitional Care Management Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions. 99495, 99496 on an RHC claim, either alone or with other payable services  If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid. Covered since January 1, 2013 


Table 2

 Medicare Policy Area  Current Policy and Duration of Flexibility/Waiver
 Originating Site/Geographic Requirements  Patients can receive telehealth services in their home or anywhere else through December 31, 2024.
 Distant Site Requirements  RHC providers can serve as telehealth distant site providers through December 31, 2024. RHC providers can offer telehealth services from any location, including their home, during this period.
 Billing/Cost Reporting Requirements  Please see table above. G2025 policy for medical telehealth visits remains in effect  through December 31, 2024.
 Modality  The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023 


Other Telehealth Information of Interest:

  • The Drug Enforcement Agency extended the flexibilities for prescribing controlled substances via telehealth through December 31, 2024.
  • HHS provided resources on educating patients on privacy and security risks when using telehealth.